In Bittner v United States, SCOTUS settled the question of the appropriate method of calculating strict liability penalties for the failure to timely disclose reportable accounts on an FBAR.
U.S. persons who have more than $10,000 in foreign bank accounts at any time in a tax year must report those accounts to the government on an FBAR. The failure to timely and properly file an FBAR can ...
The IRS received a significant increase in operating funds after Congress passed the Inflation Reduction Act (IRA) in mid-2022. More recently, on September 8, 2023, the IRS announced that it would use ...
Under the Bank Secrecy Act, U.S. taxpayers must file an FBAR (FinCEN Form 114) if their foreign financial account balances exceed $10,000 in aggregate at any point during a calendar year. A failure to ...
June 30 is the deadline for filing the current year Report of Foreign Bank and Financial Accounts, Treasury Form TD F 90-22.1 (FBAR). “United States persons” having a financial interest in or ...
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received ...
The maximum civil penalty for non-willful failure to comply with FBAR reporting requirements is $10,000. 1 However, additional penalties may apply for willful violations. Penalties for a willful ...
IRVINE, Calif., April 14, 2023 /PRNewswire/ -- U.S. citizens who hold foreign bank accounts valuing more than $10,000 on any day of the year are required to report file a Report of Foreign Bank and ...
The IRS announced Friday in Notice 2009-62 that it is extending for certain taxpayers the due date for filing calendar year 2008 Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR) ...
The Report of Foreign Bank and Financial Account, or FBAR, is an annual informational tax report that must be filed by certain U.S. individuals and legal entities to report their foreign bank accounts ...
On Feb. 28, 2023, the U.S. Supreme Court issued its opinion in Bittner v. United States, which focused on the correct penalty amount for non-willful violations of the foreign bank and financial ...
For over a decade, the Internal Revenue Service and the U.S. Department of Justice have devoted substantial resources to cracking down on taxpayers who fail to disclose their offshore accounts on ...